Privacy Policy

1. Introduction

smoothcvvh B.V. ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website smoothcvvh.live, use our services, or interact with us. This policy complies with the General Data Protection Regulation (GDPR) and other applicable data protection laws in the European Union.

2. Data Controller

smoothcvvh B.V. is the Data Controller for the personal data processed under this Privacy Policy. Our contact details are:

3. Data Collection

The data we collect includes personal information that you provide directly to us and information that we collect automatically when you interact with our website and services. We collect the following types of information:

3.1 Information You Provide

• Contact information (name, email address, phone number, company name)
• Communication preferences and marketing consents
• Information in correspondence and communications with us
• Project requirements and business information when requesting services
• Payment information (processed securely by third-party payment processors)

3.2 Information We Collect Automatically

• Website usage data (pages visited, time spent, click patterns)
• Device information (IP address, browser type, operating system)
• Cookies and similar tracking technologies (see our Cookie Policy)
• Referral sources and website analytics data

4. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal bases:

• Consent: When you provide explicit consent for marketing communications or cookies
• Contract: To perform our services and fulfil contractual obligations
• Legitimate Interest: For website analytics, security, and business operations
• Legal Obligation: To comply with legal and regulatory requirements

5. How We Use Your Information

We explain how we use your information for various purposes related to our business operations and service delivery:

• Providing and delivering our data analytics services
• Responding to your inquiries and customer support requests
• Processing payments and managing client relationships
• Improving our website, services, and user experience
• Sending marketing communications (with your consent)
• Complying with legal obligations and protecting our rights
• Conducting business analytics and performance monitoring

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following circumstances:

• With trusted service providers who assist in our operations (cloud hosting, email services, analytics)
• When required by law, legal process, or regulatory authorities
• To protect our rights, property, or safety, or that of others
• In connection with business transfers or mergers (with appropriate safeguards)
• With your explicit consent for specific purposes

7. International Data Transfers

Your personal data is primarily processed within the European Union. When we transfer data outside the EU, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions by the European Commission.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy:

• Client data: For the duration of our business relationship plus 7 years for legal and accounting purposes
• Marketing data: Until you withdraw consent or we determine it's no longer necessary
• Website analytics: Typically 26 months, as configured in our analytics tools
• Contact inquiries: Up to 3 years unless a business relationship develops

9. Your Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data in certain circumstances
• Right to Restrict Processing: Request limitation of processing
• Right to Data Portability: Request transfer of data to another controller
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for consent-based processing

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training on data protection.

11. Cookies and Tracking

Our website uses cookies and similar tracking technologies. Please refer to our Cookie Policy for detailed information about the cookies we use and how to manage your preferences.

12. Children's Privacy

Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware that we have collected such information, we will take steps to delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy, want to exercise your rights, or need to contact us regarding data protection matters, please contact us at:

15. Supervisory Authority

If you believe we have not addressed your data protection concerns adequately, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or your local supervisory authority.